ML18037A984
| ML18037A984 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/11/1994 |
| From: | Machon R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9407180194 | |
| Download: ML18037A984 (13) | |
Text
J. JWA~ LWL L L J.
(ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9407180194 DOC.DATE: 94/07/11 NOTARXZED: NO FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Bfowns Ferry Nuclear Power Station, Unit 3, Tennessee AUTH.NAME AUTHOR AFFILIATION MACHON,R.D.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 940610 ltr re violations noted in insp rept 50-259/92-09
& 50-260/92-09
& 50-296/92-09.Corrective actions:meeting was conducted by site security manager.
DISTRXBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
DOCKET 05000259 05000260 05000296 p
RECIPXENT ID CODE/NAME PD2-4-PD WILLIAMS,J.
INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E O~DI-'R RE@'2 RGN2 FILE 01 EXTERNAL: EG&G/BRYCE,J. H.
NSIC COPIES LTTR ENCL 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1.
RECIPIENT ID CODE/NAME TRXMBLE,D AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS3 RES/HFB NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
~ 1 1
1 1
~
1 D
C NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS I<<OR DOCUMENTS YOU DON'T NEED!
0 0
Tennessee VaseyAutnonty. Post Offce Box 2000, Decatur, Atabanta 35609-2000 R. D. (Rick) Machon Vce Present, Browns Ferry Nuofear Ptant July ll, 1994 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555 Gentlemen:
In the Matter of
)
Tennessee Valley Authority
)
Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BEN) - NRC INSPECTION REPORT NOS.
50-259/92-09, 50-260/92-09, AND 50-296/92-09 AND NRC OFFICE OF INVESTIGATIONS REPORT NO. 2-92-003R REPLY TO NOTICE OF VIOLATION (NOV)
This letter provides TVA's reply to the NOV transmitted by letter dated June 10,
- 1994, from S.
D. Ebneter to O.
D. Kingsley.
The NOV cites TVA for a Severity Level IV violation in connection with a failure to comply with procedural requirements governing control of access to protected and vital areas.
The enclosure to this letter contains TVA's response to the cited violation.
If you have any questions regarding this response, please telephone Pedro Salas at (205) 729-2636.
Sincerely, R.
D.
achon Site Vice President PAB 1G-BFN Enclosure cc:
See page 2
'tt407180194 940711 PDR ADOCK 05000259 Q
U.S. Nuclear Regulatory Commission Page 2
July 11, 1994 Enclosure cc (Enclosure):
Mr. Mark S. Lesser, Section Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Brovns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. J.
F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D.
C. Trimble, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D. R. McGuire Safeguards Section Chief Region II 101 Marietta Street, NW, Suite 2900
- Atlanta, GA 30323
e ENCLOSURE 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
REPLY TO NOTICE OF VIOLATION (NOV)
INSPECT10N TO NOTXCE OF VXOLATZON NUMBERS 50-259/92 09~ 50-260/92-09'0 296/92-09 AND OFFXCE OF 1NVESTXGATIONS REPORT NUMBER 2-92-003R VIOLATION "During an NRC inspection conducted on March 9 through 13,
- 1992, and an investigation completed on April 15, 1993 by the NRC Office of Investigations, a violation of NRC requirements was identified.
In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C, the violation is listed below:
Section 6.8.1 of the licensee's Technical Specifications requires that written procedures shall be established, implemented and maintained regarding security plan implementation.
Browns Ferry Nuclear Plant Site Director Standard Practice SDSP-ll.5, Revision 6, dated February 2, 1991, a procedure which implements, in part, the access provisions of the Security Plan, requires:
In Section 6.15, employment shall normal operating Shift Supervisor holidays.
that personnel who are terminating check-out with Plant Access during hours and with the Nuclear Security during off shift, weekends and In Section 7.0, that supervisors immediately notify Nuclear Security of any action that affects escorted or unescorted access to the protected area and ensure that contractors follow check-out procedures.
Contrary to the above, as of May 22,
- 1991, two contract employees whose employment at the BFN was terminated on April 15 and 19, 1991, respectively, failed to check-out with Plant Access as required by SDSP-11.5, and the supervisors of the two terminated contract employees failed to notify Nuclear Security of the employees'ermination and did not ensure that the terminated contract employees followed check-out procedures.
Termination of an employee is an action that revokes the employee's unescorted access
E I
This 1 ~
to the site protected and vital areas.
As a result, the terminated employees'ecurity badges and vital area key cards remained active and were subsequently used by the terminated contract employees to gain unauthorized access to the protected area on two occasions.
is a,Severity Level IV violation (Supplement III)."
Reason for the Violation On May 22,
- 1991, TVA identified, through use of a 31-day authorization access list, two individuals who had terminated their contract obligations with Bechtel Corporation, yet whose picture identification badges authorizing unescorted access remained available for use.
Records reviewed at the time of discovery showed that one individual had used his badge to enter the Protected Area (PA) on two occasions subsequent to contract termination.
It was later determined that the other contract employee also had entered the PA on two occasions subsequent to contract termination.
Plant Access immediately pulled the individuals'adges and notified Site Security.
The reason for the Severity Level IV violation is two-fold.
First, the employees'upervisors lacked knowledge of out-processing requirements and failed to ensure that terminated employees complied with out-processing procedures.
- Second, the two Bechtel employees failed to follow SDSP-32.6, "Processing Employee in and out of Nuclear Power," upon termination.
They had been informed of their check-out responsibility and corresponding procedural requirements, but did not follow them.
Three factors contributed to the violation.
- First, existing procedures were not effectively implemented because they were unclear and contradictory in terms of assigning check-out responsibility.
The procedures did not provide for a single point of responsibility.
The supervisors placed the responsibility for check-out solely on the two Bechtel employees and did not follow-up to determine whether the employees had in fact checked-out.
- Second, the procedures inadequately ensured the proper check-out of terminated employees.
There was no formal Bechtel check-out procedure and the'FN procedure did not require that Human Resources be notified of employees who were required to check-out.
Finally, the contractors apparently entered the PA deliberately in order to keep their access/badges active and, for this reason, did not adhere to the established check-out process.
Regardless of the contractors'ntentions or the deliberate nature of their actions, however, the situation should have been prevented by an effective, clearly-defined process.
0 0
t d
2.
Corrective Actions Taken and Results Ach'eyed Immediately following discovery of the contract employees'ailure to adhere to access control procedures, their badges were removed from the badge rack.
In addition, an investigation of the events was promptly initiated.
Subsequent corrective actions were taken to ensure that (1) supervisors understand out-processing requirements and ensure that terminated employees comply with such requirements; and (2) personnel granted unescorted access to the protected areas of BFN are trained and sensitized to the responsibilities inherent in authorized access.
A meeting was conducted by the Site Security Manager in July 1991, with Restart Managers regarding proper access authorization control (the check-in/check-out process).
The managers were advised about the failure of terminated contract employees to adhere to check-out procedures which resulted in unescorted badges remaining in an active status in the access control portals.
The significance of the issue, as well as the importance of procedure adherence, was emphasized by the Security Manager.
Bechtel and other major contractors developed procedures, subject to TVA approval, for in-processing and check-out of terminated employees.
The purpose in doing so was to ensure compliance with SDSP-32.6 and BP-108.
As part of this process, TVA contractors were required to assign sponsors for professional support personnel who are directly accountable for access control.
The Site Vice President issued a follow-up memorandum in March 1992, re-emphasizing the check-out requirements of BP-108.
In addition, BP-108, a corporate business
- practice, was made site-specific to BFN through the issuance of BP-308 in May 1992.
E1-3
0'
The following corrective actions were initiated pursuant to CAQR BFP 910192:
The proper methodology for out-processing was clarified in Employee Check-out Procedures (BP-108/SDSP-32.6).
BP-108 was revised in November 1991, to clarify that all Supervisors, whether contract, salary policy, hourly, TVA permanent, or temporary, are responsible for ensuring that terminated personnel under their supervision are out-processed in 'accordance with procedures on a timely basis.
On August 20,
- 1991, a
BFN Dispatch was issued to site employees summarizing the revised check-out requirements specified in BP-108 and noting the BP ensures that supervisors verify that employees complete the check-out process.
On July 22) 1991( Site Security requested that the BFN Training Section inform employees, in the context of General Employee Training (GET), about the serious consequences (five year employment block at TVA facilities) that will occur if an employee fails to
. adhere to the check-out procedures specified in BP-108.
The requested addition of check-out requirements in GET was accomplished through the GET 10 revision in September 1991.
By memorandum dated September 6 and 10, 1991, the BFN Interim Security Manager contacted TVA and contract administrators and informed them of the need for employees and supervisors to complete the check-out process specified in BP-108.
Included in the memorandam was a copy of BP-108 and a summary briefing outlining (1) employee and supervisor check-out responsibilities; and (2) the corrective actions that will be taken against any employee/supervisor who fails to adhere to BP-108.
The memorandam further directed the contractors to brief their personnel about the procedures and penalties.
In conjunction with distribution of the memoranda, TVA conducted a contractors meeting on September 6,
- 1991, in which it discussed contractors'rganizational responsibilities for adherence to proper check-in/check-out processes.
Another memorandum, dated October 10,
- 1991, from the Interim Security Manager to all contract administrators advised them of the need to attend a briefing to discuss methods to prevent recurrence of check-out violations.
The meeting was held, as scheduled, on October 29, 1991.
A Security instruction bulletin has been prepared for issue to each new employee upon check-in.
The purpose
0'
3 ~
of the instruction is to assist new employees using the Security Access Control System.
Among the subjects addressed in the instruction are check-out requirements.
Corrective Actions That Will Be Taken To Avoid Further Violations 4 ~
No additional corrective steps are required in connection with this violation.
Date When Pull Com liance Will Be Achieved TVA believes that full compliance has been achieved.
E1-5